Implementation v. Adaptation : BEPS in Latin America Through the Lens of the ILADT Model

There are specific reasons to affirm that the base erosion and profit shifting (BEPS) Project is not fully suited to addressing the needs of Latin American countries. Therefore, adaptations to several of the BEPS Actions included in the Project are necessary. The drafting of the Multilateral Instrument (MLI) as proposed in BEPS Action 15 could constitute a proper scenario for submitting and addressing the specific concerns and proposals of the region with respect to the BEPS Project. The author proposes the use of the ILADT Model (Instituto Latinoamericano de Derecho Tributario - Latin American Institute of Tax Law) to address, systematize and generate a sole proposal for the region in order to represent the needs of the region in the drafting of the MLI.Full-text Paper